On October 30, 1966, Bridgeport, Connecticut police sergeant, John Connolly, was driving as part of his early morning patrol duty.

During trial, Williams attempted to suppress the evidence on the basis that the State of Connecticut could not demonstrate the reliability of the informant, and that Connoly did not observe him in plain view outside the car.

However, an en banc hearing from the latter court reversed Williams' conviction because Conolly did not have reasonable suspicion to reach into his waistband.

Previous interactions with Connolly and the informant concerned "public homosexual activities" at a railway station where a followup investigation resulted in no arrests.

Frederick D. Lewis Jr., a former Dean for the University of Miami School of Law,[6][7] criticized the majority opinion for potentially deviating from Carroll v. United States and Chimel v. California by declaring a vehicle as an area to be searched incident to arrest.

[8] While the majority decision in Adams differentiated Williams' circumstances from the events in the Aguilar and Spinelli cases, the latter two were later overturned under Illinois v. Gates.